Criteria or Specific Requirement:
In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use
its own documented procurement procedures which reflect applicable State, local, and tribal laws
and regulations, provided that the procurements conform to applicable federal law and the
standards identified in General Procurement Standards. Additionally, §200.318(i) states that the
non-federal entity must maintain records sufficient to detail the history of the procurement. These
records are required to include but are not necessarily limited to the following: rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis
for the contract price. All procurement transactions must be conducted in a manner providing full
and open competition consistent in accordance with §200.319 and must be performed using the
appropriate procurement method as outlined in §200.320.
In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot
enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or
otherwise excluded from or ineligible for participation in federal assistance programs or activities.
Non-federal entities must either check for exclusions in the System for Award Management (SAM);
collect a certification from the entity, or add a clause or condition to the covered transaction with
the entity prior to entering into a covered transaction with a non-federal entity. In addition, in
accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions
(other than no-cost time extension) with any excluded person, or under which an excluded person
is a principal, unless the non-federal entity obtains an exception under §180.135.
Condition: During our compliance testing of the procurement compliance requirement, with respect
to ALN # 19.345, for one (1) sample of eleven samples selected for testing, the Organization
amended the contract to extend the end date and adjust pricing before verifying and documenting
that the vendor was not suspended or debarred. For ALN #19.501, for two (2) samples of the three
samples tested, the Organization signed amendments in November 2023 and July 2024, before
verifying and documenting that the vendor was not suspended or debarred. The last verification was
performed in May 2022.
Cause: The Organization did not perform proper suspension and debarment validations when the
amendment to the agreement was signed.
Effect: Failure to perform procurement procedures in accordance with a written policy that
complies with Procurement Procedures as outlined in the Uniform Administrative Requirements
could result in the procurement being disallowed. Failure to timely verify that a vendor is not
suspended or debarred could result in transactions involving unreasonable costs or result in
unintentionally entering into a contract with an entity that is barred from performing work for the
U.S. government.
Questioned Costs: None.
Context: This is a condition based on testing of the Organization’s compliance with specified
requirements. The prevalence of these findings is detailed in the condition section above. The
samples were selected using a random sampling method.
Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2023-
003 in the 2023 Schedule of Findings and Questioned Costs.
Recommendation: We recommend that management strengthen the procurement policy to align
with the Procurement Procedures outlined in the Uniform Administrative Requirements.
Additionally, we suggest providing all staff with additional training on this policy to ensure
compliance in the future.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
Criteria or Specific Requirement:
In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use
its own documented procurement procedures which reflect applicable State, local, and tribal laws
and regulations, provided that the procurements conform to applicable federal law and the
standards identified in General Procurement Standards. Additionally, §200.318(i) states that the
non-federal entity must maintain records sufficient to detail the history of the procurement. These
records are required to include but are not necessarily limited to the following: rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis
for the contract price. All procurement transactions must be conducted in a manner providing full
and open competition consistent in accordance with §200.319 and must be performed using the
appropriate procurement method as outlined in §200.320.
In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot
enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or
otherwise excluded from or ineligible for participation in federal assistance programs or activities.
Non-federal entities must either check for exclusions in the System for Award Management (SAM);
collect a certification from the entity, or add a clause or condition to the covered transaction with
the entity prior to entering into a covered transaction with a non-federal entity. In addition, in
accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions
(other than no-cost time extension) with any excluded person, or under which an excluded person
is a principal, unless the non-federal entity obtains an exception under §180.135.
Condition: During our compliance testing of the procurement compliance requirement, with respect
to ALN # 19.345, for one (1) sample of eleven samples selected for testing, the Organization
amended the contract to extend the end date and adjust pricing before verifying and documenting
that the vendor was not suspended or debarred. For ALN #19.501, for two (2) samples of the three
samples tested, the Organization signed amendments in November 2023 and July 2024, before
verifying and documenting that the vendor was not suspended or debarred. The last verification was
performed in May 2022.
Cause: The Organization did not perform proper suspension and debarment validations when the
amendment to the agreement was signed.
Effect: Failure to perform procurement procedures in accordance with a written policy that
complies with Procurement Procedures as outlined in the Uniform Administrative Requirements
could result in the procurement being disallowed. Failure to timely verify that a vendor is not
suspended or debarred could result in transactions involving unreasonable costs or result in
unintentionally entering into a contract with an entity that is barred from performing work for the
U.S. government.
Questioned Costs: None.
Context: This is a condition based on testing of the Organization’s compliance with specified
requirements. The prevalence of these findings is detailed in the condition section above. The
samples were selected using a random sampling method.
Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2023-
003 in the 2023 Schedule of Findings and Questioned Costs.
Recommendation: We recommend that management strengthen the procurement policy to align
with the Procurement Procedures outlined in the Uniform Administrative Requirements.
Additionally, we suggest providing all staff with additional training on this policy to ensure
compliance in the future.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities
receiving Federal awards (i.e., auditee management) establish and maintain internal control
designed to reasonably ensure compliance with Federal statues, regulations, and the terms and
conditions of the Federal award.
In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and
Transparency Act (FFATA), the department is required to collect and report information on each
subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting
System. The non-Federal entity or Federal agency must report each obligating action described in
paragraph a.1. of this award term to http://www.fsrs.gov.
In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is
responsible for complying with all requirements of the Federal award. For all Federal awards, this
includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance
Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting
Subaward and Executive Compensation Information.
Condition: During our subrecipient testing for the major program, we were unable to verify the
submission dates of the FFATA Report via the Federal Funding Accountability and Transparency Act
Subaward Reporting System (FSRS) website. The Organization was unable to provide evidence of
submission, lacking retained documentation that evidenced the actual submission dates of the
FFATA reports.
Cause: It was determined that the absence of supporting documentation was a result of the FSRS
system migration to SAM.gov. The Organization neglected to keep documentation to support
submission.
Effect: The inability to verify the submission dates of the FFATA reports due to missing
documentation may lead to compliance issues with federal reporting requirements.
Questioned Costs: None.
Context: This is a condition identified per review of the Organization’s compliance with the
reporting provisions of the Uniform Guidance.
Repeat Finding: This finding is not a repeat finding from the prior year.
Recommendation: BDO recommends that the Organization establish a comprehensive system for
retaining submission records, including timestamps and confirmation receipts, to ensure all future
FFATA report submissions are verifiable.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities
receiving Federal awards (i.e., auditee management) establish and maintain internal control
designed to reasonably ensure compliance with Federal statues, regulations, and the terms and
conditions of the Federal award.
In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and
Transparency Act (FFATA), the department is required to collect and report information on each
subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting
System. The non-Federal entity or Federal agency must report each obligating action described in
paragraph a.1. of this award term to http://www.fsrs.gov.
In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is
responsible for complying with all requirements of the Federal award. For all Federal awards, this
includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance
Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting
Subaward and Executive Compensation Information.
Condition: During our subrecipient testing for the major program, we were unable to verify the
submission dates of the FFATA Report via the Federal Funding Accountability and Transparency Act
Subaward Reporting System (FSRS) website. The Organization was unable to provide evidence of
submission, lacking retained documentation that evidenced the actual submission dates of the
FFATA reports.
Cause: It was determined that the absence of supporting documentation was a result of the FSRS
system migration to SAM.gov. The Organization neglected to keep documentation to support
submission.
Effect: The inability to verify the submission dates of the FFATA reports due to missing
documentation may lead to compliance issues with federal reporting requirements.
Questioned Costs: None.
Context: This is a condition identified per review of the Organization’s compliance with the
reporting provisions of the Uniform Guidance.
Repeat Finding: This finding is not a repeat finding from the prior year.
Recommendation: BDO recommends that the Organization establish a comprehensive system for
retaining submission records, including timestamps and confirmation receipts, to ensure all future
FFATA report submissions are verifiable.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
2024-001 Internal Control over Compliance and Compliance with Reporting
Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial
reports as required by the Federal award. Reports submitted annually by the recipient or
subrecipient must be due no later than 90 calendar days after the reporting period. Reports
submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting
period.”
Condition: The internal controls implemented to ensure the timely submission of the quarterly
financial report and quarterly performance report within 30 days after the end of the reporting
period did not function as intended. During our testing of reporting compliance, BDO noted that the
following reports were not submitted on time due to staff unavailability for preparation and
submission:
• One financial report (quarter 1) for ALN 19.801
• One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001
Cause: The Organization's internal controls, designed to ensure compliance with reporting
regulations, failed to function as intended. As a result, they did not effectively address the
requirement to submit financial reports in a timely manner and meet the established deadlines.
Effect: The failure of the Organization's internal controls to operate as designed has led to delays
in the submission of the required financial reports, potentially resulting in non-compliance with the
requirements of CFR Section §200.328(c).
Questioned Costs: None.
Context: The nature of these findings is detailed in the condition section above.
Repeat Finding: This finding is not a repeat finding from prior year.
Recommendation: We recommend that management evaluate the current controls to confirm they
are strong and capable of effectively meeting the requirements for timely financial report
submission. Additionally, management should ensure there are sufficient staff members available
to prepare and submit the reports.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
2024-001 Internal Control over Compliance and Compliance with Reporting
Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial
reports as required by the Federal award. Reports submitted annually by the recipient or
subrecipient must be due no later than 90 calendar days after the reporting period. Reports
submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting
period.”
Condition: The internal controls implemented to ensure the timely submission of the quarterly
financial report and quarterly performance report within 30 days after the end of the reporting
period did not function as intended. During our testing of reporting compliance, BDO noted that the
following reports were not submitted on time due to staff unavailability for preparation and
submission:
• One financial report (quarter 1) for ALN 19.801
• One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001
Cause: The Organization's internal controls, designed to ensure compliance with reporting
regulations, failed to function as intended. As a result, they did not effectively address the
requirement to submit financial reports in a timely manner and meet the established deadlines.
Effect: The failure of the Organization's internal controls to operate as designed has led to delays
in the submission of the required financial reports, potentially resulting in non-compliance with the
requirements of CFR Section §200.328(c).
Questioned Costs: None.
Context: The nature of these findings is detailed in the condition section above.
Repeat Finding: This finding is not a repeat finding from prior year.
Recommendation: We recommend that management evaluate the current controls to confirm they
are strong and capable of effectively meeting the requirements for timely financial report
submission. Additionally, management should ensure there are sufficient staff members available
to prepare and submit the reports.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
2024-001 Internal Control over Compliance and Compliance with Reporting
Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial
reports as required by the Federal award. Reports submitted annually by the recipient or
subrecipient must be due no later than 90 calendar days after the reporting period. Reports
submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting
period.”
Condition: The internal controls implemented to ensure the timely submission of the quarterly
financial report and quarterly performance report within 30 days after the end of the reporting
period did not function as intended. During our testing of reporting compliance, BDO noted that the
following reports were not submitted on time due to staff unavailability for preparation and
submission:
• One financial report (quarter 1) for ALN 19.801
• One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001
Cause: The Organization's internal controls, designed to ensure compliance with reporting
regulations, failed to function as intended. As a result, they did not effectively address the
requirement to submit financial reports in a timely manner and meet the established deadlines.
Effect: The failure of the Organization's internal controls to operate as designed has led to delays
in the submission of the required financial reports, potentially resulting in non-compliance with the
requirements of CFR Section §200.328(c).
Questioned Costs: None.
Context: The nature of these findings is detailed in the condition section above.
Repeat Finding: This finding is not a repeat finding from prior year.
Recommendation: We recommend that management evaluate the current controls to confirm they
are strong and capable of effectively meeting the requirements for timely financial report
submission. Additionally, management should ensure there are sufficient staff members available
to prepare and submit the reports.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
Criteria or Specific Requirement:
In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use
its own documented procurement procedures which reflect applicable State, local, and tribal laws
and regulations, provided that the procurements conform to applicable federal law and the
standards identified in General Procurement Standards. Additionally, §200.318(i) states that the
non-federal entity must maintain records sufficient to detail the history of the procurement. These
records are required to include but are not necessarily limited to the following: rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis
for the contract price. All procurement transactions must be conducted in a manner providing full
and open competition consistent in accordance with §200.319 and must be performed using the
appropriate procurement method as outlined in §200.320.
In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot
enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or
otherwise excluded from or ineligible for participation in federal assistance programs or activities.
Non-federal entities must either check for exclusions in the System for Award Management (SAM);
collect a certification from the entity, or add a clause or condition to the covered transaction with
the entity prior to entering into a covered transaction with a non-federal entity. In addition, in
accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions
(other than no-cost time extension) with any excluded person, or under which an excluded person
is a principal, unless the non-federal entity obtains an exception under §180.135.
Condition: During our compliance testing of the procurement compliance requirement, with respect
to ALN # 19.345, for one (1) sample of eleven samples selected for testing, the Organization
amended the contract to extend the end date and adjust pricing before verifying and documenting
that the vendor was not suspended or debarred. For ALN #19.501, for two (2) samples of the three
samples tested, the Organization signed amendments in November 2023 and July 2024, before
verifying and documenting that the vendor was not suspended or debarred. The last verification was
performed in May 2022.
Cause: The Organization did not perform proper suspension and debarment validations when the
amendment to the agreement was signed.
Effect: Failure to perform procurement procedures in accordance with a written policy that
complies with Procurement Procedures as outlined in the Uniform Administrative Requirements
could result in the procurement being disallowed. Failure to timely verify that a vendor is not
suspended or debarred could result in transactions involving unreasonable costs or result in
unintentionally entering into a contract with an entity that is barred from performing work for the
U.S. government.
Questioned Costs: None.
Context: This is a condition based on testing of the Organization’s compliance with specified
requirements. The prevalence of these findings is detailed in the condition section above. The
samples were selected using a random sampling method.
Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2023-
003 in the 2023 Schedule of Findings and Questioned Costs.
Recommendation: We recommend that management strengthen the procurement policy to align
with the Procurement Procedures outlined in the Uniform Administrative Requirements.
Additionally, we suggest providing all staff with additional training on this policy to ensure
compliance in the future.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
Criteria or Specific Requirement:
In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use
its own documented procurement procedures which reflect applicable State, local, and tribal laws
and regulations, provided that the procurements conform to applicable federal law and the
standards identified in General Procurement Standards. Additionally, §200.318(i) states that the
non-federal entity must maintain records sufficient to detail the history of the procurement. These
records are required to include but are not necessarily limited to the following: rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis
for the contract price. All procurement transactions must be conducted in a manner providing full
and open competition consistent in accordance with §200.319 and must be performed using the
appropriate procurement method as outlined in §200.320.
In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot
enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or
otherwise excluded from or ineligible for participation in federal assistance programs or activities.
Non-federal entities must either check for exclusions in the System for Award Management (SAM);
collect a certification from the entity, or add a clause or condition to the covered transaction with
the entity prior to entering into a covered transaction with a non-federal entity. In addition, in
accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions
(other than no-cost time extension) with any excluded person, or under which an excluded person
is a principal, unless the non-federal entity obtains an exception under §180.135.
Condition: During our compliance testing of the procurement compliance requirement, with respect
to ALN # 19.345, for one (1) sample of eleven samples selected for testing, the Organization
amended the contract to extend the end date and adjust pricing before verifying and documenting
that the vendor was not suspended or debarred. For ALN #19.501, for two (2) samples of the three
samples tested, the Organization signed amendments in November 2023 and July 2024, before
verifying and documenting that the vendor was not suspended or debarred. The last verification was
performed in May 2022.
Cause: The Organization did not perform proper suspension and debarment validations when the
amendment to the agreement was signed.
Effect: Failure to perform procurement procedures in accordance with a written policy that
complies with Procurement Procedures as outlined in the Uniform Administrative Requirements
could result in the procurement being disallowed. Failure to timely verify that a vendor is not
suspended or debarred could result in transactions involving unreasonable costs or result in
unintentionally entering into a contract with an entity that is barred from performing work for the
U.S. government.
Questioned Costs: None.
Context: This is a condition based on testing of the Organization’s compliance with specified
requirements. The prevalence of these findings is detailed in the condition section above. The
samples were selected using a random sampling method.
Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2023-
003 in the 2023 Schedule of Findings and Questioned Costs.
Recommendation: We recommend that management strengthen the procurement policy to align
with the Procurement Procedures outlined in the Uniform Administrative Requirements.
Additionally, we suggest providing all staff with additional training on this policy to ensure
compliance in the future.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities
receiving Federal awards (i.e., auditee management) establish and maintain internal control
designed to reasonably ensure compliance with Federal statues, regulations, and the terms and
conditions of the Federal award.
In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and
Transparency Act (FFATA), the department is required to collect and report information on each
subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting
System. The non-Federal entity or Federal agency must report each obligating action described in
paragraph a.1. of this award term to http://www.fsrs.gov.
In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is
responsible for complying with all requirements of the Federal award. For all Federal awards, this
includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance
Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting
Subaward and Executive Compensation Information.
Condition: During our subrecipient testing for the major program, we were unable to verify the
submission dates of the FFATA Report via the Federal Funding Accountability and Transparency Act
Subaward Reporting System (FSRS) website. The Organization was unable to provide evidence of
submission, lacking retained documentation that evidenced the actual submission dates of the
FFATA reports.
Cause: It was determined that the absence of supporting documentation was a result of the FSRS
system migration to SAM.gov. The Organization neglected to keep documentation to support
submission.
Effect: The inability to verify the submission dates of the FFATA reports due to missing
documentation may lead to compliance issues with federal reporting requirements.
Questioned Costs: None.
Context: This is a condition identified per review of the Organization’s compliance with the
reporting provisions of the Uniform Guidance.
Repeat Finding: This finding is not a repeat finding from the prior year.
Recommendation: BDO recommends that the Organization establish a comprehensive system for
retaining submission records, including timestamps and confirmation receipts, to ensure all future
FFATA report submissions are verifiable.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities
receiving Federal awards (i.e., auditee management) establish and maintain internal control
designed to reasonably ensure compliance with Federal statues, regulations, and the terms and
conditions of the Federal award.
In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and
Transparency Act (FFATA), the department is required to collect and report information on each
subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting
System. The non-Federal entity or Federal agency must report each obligating action described in
paragraph a.1. of this award term to http://www.fsrs.gov.
In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is
responsible for complying with all requirements of the Federal award. For all Federal awards, this
includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance
Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting
Subaward and Executive Compensation Information.
Condition: During our subrecipient testing for the major program, we were unable to verify the
submission dates of the FFATA Report via the Federal Funding Accountability and Transparency Act
Subaward Reporting System (FSRS) website. The Organization was unable to provide evidence of
submission, lacking retained documentation that evidenced the actual submission dates of the
FFATA reports.
Cause: It was determined that the absence of supporting documentation was a result of the FSRS
system migration to SAM.gov. The Organization neglected to keep documentation to support
submission.
Effect: The inability to verify the submission dates of the FFATA reports due to missing
documentation may lead to compliance issues with federal reporting requirements.
Questioned Costs: None.
Context: This is a condition identified per review of the Organization’s compliance with the
reporting provisions of the Uniform Guidance.
Repeat Finding: This finding is not a repeat finding from the prior year.
Recommendation: BDO recommends that the Organization establish a comprehensive system for
retaining submission records, including timestamps and confirmation receipts, to ensure all future
FFATA report submissions are verifiable.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
2024-001 Internal Control over Compliance and Compliance with Reporting
Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial
reports as required by the Federal award. Reports submitted annually by the recipient or
subrecipient must be due no later than 90 calendar days after the reporting period. Reports
submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting
period.”
Condition: The internal controls implemented to ensure the timely submission of the quarterly
financial report and quarterly performance report within 30 days after the end of the reporting
period did not function as intended. During our testing of reporting compliance, BDO noted that the
following reports were not submitted on time due to staff unavailability for preparation and
submission:
• One financial report (quarter 1) for ALN 19.801
• One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001
Cause: The Organization's internal controls, designed to ensure compliance with reporting
regulations, failed to function as intended. As a result, they did not effectively address the
requirement to submit financial reports in a timely manner and meet the established deadlines.
Effect: The failure of the Organization's internal controls to operate as designed has led to delays
in the submission of the required financial reports, potentially resulting in non-compliance with the
requirements of CFR Section §200.328(c).
Questioned Costs: None.
Context: The nature of these findings is detailed in the condition section above.
Repeat Finding: This finding is not a repeat finding from prior year.
Recommendation: We recommend that management evaluate the current controls to confirm they
are strong and capable of effectively meeting the requirements for timely financial report
submission. Additionally, management should ensure there are sufficient staff members available
to prepare and submit the reports.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
2024-001 Internal Control over Compliance and Compliance with Reporting
Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial
reports as required by the Federal award. Reports submitted annually by the recipient or
subrecipient must be due no later than 90 calendar days after the reporting period. Reports
submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting
period.”
Condition: The internal controls implemented to ensure the timely submission of the quarterly
financial report and quarterly performance report within 30 days after the end of the reporting
period did not function as intended. During our testing of reporting compliance, BDO noted that the
following reports were not submitted on time due to staff unavailability for preparation and
submission:
• One financial report (quarter 1) for ALN 19.801
• One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001
Cause: The Organization's internal controls, designed to ensure compliance with reporting
regulations, failed to function as intended. As a result, they did not effectively address the
requirement to submit financial reports in a timely manner and meet the established deadlines.
Effect: The failure of the Organization's internal controls to operate as designed has led to delays
in the submission of the required financial reports, potentially resulting in non-compliance with the
requirements of CFR Section §200.328(c).
Questioned Costs: None.
Context: The nature of these findings is detailed in the condition section above.
Repeat Finding: This finding is not a repeat finding from prior year.
Recommendation: We recommend that management evaluate the current controls to confirm they
are strong and capable of effectively meeting the requirements for timely financial report
submission. Additionally, management should ensure there are sufficient staff members available
to prepare and submit the reports.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.
2024-001 Internal Control over Compliance and Compliance with Reporting
Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial
reports as required by the Federal award. Reports submitted annually by the recipient or
subrecipient must be due no later than 90 calendar days after the reporting period. Reports
submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting
period.”
Condition: The internal controls implemented to ensure the timely submission of the quarterly
financial report and quarterly performance report within 30 days after the end of the reporting
period did not function as intended. During our testing of reporting compliance, BDO noted that the
following reports were not submitted on time due to staff unavailability for preparation and
submission:
• One financial report (quarter 1) for ALN 19.801
• One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001
Cause: The Organization's internal controls, designed to ensure compliance with reporting
regulations, failed to function as intended. As a result, they did not effectively address the
requirement to submit financial reports in a timely manner and meet the established deadlines.
Effect: The failure of the Organization's internal controls to operate as designed has led to delays
in the submission of the required financial reports, potentially resulting in non-compliance with the
requirements of CFR Section §200.328(c).
Questioned Costs: None.
Context: The nature of these findings is detailed in the condition section above.
Repeat Finding: This finding is not a repeat finding from prior year.
Recommendation: We recommend that management evaluate the current controls to confirm they
are strong and capable of effectively meeting the requirements for timely financial report
submission. Additionally, management should ensure there are sufficient staff members available
to prepare and submit the reports.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.